ML20234B001

Requests Addl Info Re Disposal of Low Level Radioactively Contaminated Sludge by Land Application,In Support of Util 870714 Submittal.Demonstration That All Pathways Considered & Assurances Concerning Possible Exposure Requested

ML20234B001
Person / Time
Site:	Point Beach
Issue date:	09/09/1987
From:	Wagner D Office of Nuclear Reactor Regulation
To:	Fay C WISCONSIN ELECTRIC POWER CO.
References
TAC-65821, TAC-65822, NUDOCS 8709180227
Download: ML20234B001 (5)

Text

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SEP 0 91987 Docket Nos. 50-266 DISTRIBUTION:

and 50-301 Docket Files / l NRC & Local PDRs  ;

PD III-3 r/f l DWigginton l GHolahan l PKreutzer l DWagner 0GC-Bethesda Mr. C. W. Fay, Vice President EJordan Nuclear Power Department JPartlow Wisconsin Electric Power Company OGC-Bethesda 231 West Michigan Street, Room 308 WMeinke Milwaukee, Wisconsin 53201

SUBJECT:

REQUEST FOR ADDITIONAL INFORMATION (RAI) - DISPOSAL 0F LOW LEVEL RADI0 ACTIVELY CONTAMINATED SLUDGE BY LAND APPLICATION (TACS65821and65822)

In conducting our review of your submittal dated July 14, 1987 (supplemented by your letter dated August 6,1987) relating to the disposal of low-level radioactive waste by land application, we have determined that the information identified in the Enclosure is needed to complete our review.

Prior to acting on licensee' requests for land disposal of slightly radioactive sludge, the staff publishes an Environmental Assessment (EA) in the Federal Register. An EA published in 49FR43137 (and previously forwarded to your staff) concerning the Duke Power Company request for approval under 10 CFR 20.302 of periodic removal and re-location of slightly contaminated sludge residues and disposal of the sludge at a state-approved land farming site contiguous to the McGuire Station site is very similar to the EA that must be developed by the staff in connection with the proposed, very similar disposal of very low level sewage sludge for Point Beach. Thus, the final Point Beach submittal should address and contain commitments for the various items treated in the McGuire EIA.

Note that under the Transportation, Disposal and Administrative Procedures Sections of the McGuire EIA, each of the 15 " bullets" refers to a licensee commitment as indicated by the words "shall be". On the other hand, some-what similar bullets from the Point Beach July 14 submittal contain only three "shall be" or "will be" statements, while at the same time using "may not be" eight times.

Your revised submittal should contain your commitments to the NRC, not to the WPDES, as to what you will do, using terms such as "shall" or "will" rather than "may." The staff will then have specific commitment conditions on which to make a determination, as was done in the case of McGuire.

8709180227 870909 PDR ADOCK 05000266 P PDR

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Due to the extensive amount of information sought in the enclosed RAI and the specific commitments which must be made prior to continuing our review, we request that one complete, extensive, and self-contained package containing the analysis and evaluation of the proposed sludge disposal, addressing these points, be submitted. Only then can the EA be prepared.

The information requested in this letter affects fewer than 10 respond-ents; therefore, OMB Clearance is not required undre Pub. L.96-511.

Sincerely,

/s  ;

David H. Wagn r, Project Manager l Project Directorate III-3 Division of Reactor Projects

Enclosure:

RAI cc: See next page 1

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Office: LA/PDI.II-3 'FM/ -3 PD/PDIII-3 Surname: P4reuther DWagner/r1 DWigginton )

Date: 09/g /87 09/ct /87 09/ /87 1

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i Mr. C. W. Fay Point Beach Nuclear Plant 1

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Wisconsin Electric Power Company Units 1 and 2 j 1

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cc: I '

i Mr. Bruce Churchill, Esq.  !

Shaw, Pittman, Potts and Trowbridge {/

2300 N Street, N.W.

Washington, DC 20037 c Mr. James J. Zach, Manager  !

Point Beach Nuclear Plant Wisconsin Electric Power Company 6610 Nuclear Road ,

)j Two Rivers, Wisconsin 54241 '

1 Town Chairman Town of Two Creeks Route 3 i(

Two Rivers, Wisconsin 54241 '

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' 4 Ch$innan

}- 1 Pu6lic Service Commission 1

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of Wisconsin i Hills Farms State Office Building l Madison, Wisconsin 53702 -

Regicnal Administrator, Region III s

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U.S. Nuclear Regulatory Consnission '

Office of Executive Director for Operations 799 Roosevelt Road Glen Ellyn, Illinois 60137 l Resident Inspector's Office U.S. Nuclear Regulatory Comission ,

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6612 Nuclear Road .' l I

Two Rivers, Wisconsin 54241

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REQUEST FOR ADDITIONAL INFORMATION (RAI)

ON POINT BEACH 'l AND 2 REQUEST FOR DISPOSAL OF LOW LEVEL RADI0 ACTIVELY CONTAMINATED SEWAGE SLUDGE BY LAND APPLICATION W

_ISCONSIN ELECTRIC POWER COMPANY UNDER 10 CFR 20.302(a)

1. Provide the answers to the following:

a. is the request for a single application or multiple applications;

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b. is the request for one year or multiple years;

c. what limits will be applied to the total activity per application per year as well as to the maximum specific activity for each application; j

2. Provide adequate demonstration that all pathways are considered and that positive constraints on access to the landspread and dispersal of the landspread are provided in compliance with requirements of 10 CFR 20.302. .

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3. The submittal of August'6,1987 provides general information relative ~

to the site but fails to provide specific commitments to the NRC relative to the disposal procedures. Revise your request to contain commitments to the NRC, not to the WPDES, as to what you 'will do, using terms such as "shall" or "will" rather than "may."  !

4. Provide information regarding how the disposal plan assures that the annual dose to any exposed individual will be kept below I mrem per year.

5. The sludge application location map contained in your July 14, 1987 letter does not correspond with the site map contained in Section l

15.7.2 of the Technical Specifications. Indicate the sludge applicat-ion sites on the site map as presented in Section 15.7.2 of the

-Technical Specifications. Furthermore, augment the map to provide detailed descriptions relative to fencing and restricted or non-restricted access to site areas.

6. Provide infonnation on how WEPCo will restrict direct grazing on company-owned property. Provide infonnation as to what controls, if any, will be placed on fishermen on Lake Michigan.

7. The July 14, 1987 submittal states that six disposal sites are "within" the Point Beach site boundary. The August 6, 1987 sub-mittal states that six sites are "within or directly adjacent" to the site boundary. Please clarify this point.

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8. WEPCo proposed to characterize the contents of the sludge storage tank by analyzing two samples. Please provide:

a. the bases for concluding that two samples from a 15,000 gallon <4 tank of sludge are suffigient to define the contamination level;

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b. the prucedure to assure these samples are representative;

c. the variability in the analysis of samples ta' ken at different times, under different conditions, and at different locations;

d. the variability of analyses Yrom tank to tank as measured on the full-tank batches associated with the six land applications of sludge already made.

9. The licensee states that three " credible" pathways hav'e been identified:

direct radiation, and milk and meat consumption from cows consuming ,

feed grown on the property. Staff experience dictates that other ~

pathways besides these three should be addressed as well. Therefor 6 provide analyses of other pathways of exposure (e.g., drinking water /

from nearby wells and inhalation of resuspended particulate), or briefly '

state why these pathways are non-existent or negligible and provide a' brief basis for this statement. Potential migration of radioisotopes from the landspread to Lake Michigan with its associated fish-and drinking water pathways, should be addressed. Similarly, questions of j other food ingestion such as crops grown for human consumption on the ,

land after one year shod 1d be discussed. i

10. In the submittals, WEPCo states that doses will be kept less than 1 mrem 1 per year. WEPCo should commit to a limiting concentration level.for the .

tank, above which sludge would not be landspread. Similarly, if the I request is to cover more than one application and/or one year, WEPCo l should commit to a maximum total actwity of contaminated sludge to be - i spread per year.

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